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Last week, this blog took a look at several key components related to the OSHA Safety Regulations that require testing and certification of certain products by a Nationally Recognized Testing Laboratories (NRTL’s) for electric vehicles. But several questions remain top of mind: 1) What process does OSHA follow when recognizing an NRTL?; and 2) What product safety test standards can an NRTL use in certifying products? These questions will be answered in today’s blog.
Q: What process does OSHA follow when recognizing an NRTL? In general, OSHA follows the "Procedures for Initial OSHA Recognition" found in Appendix A to 29 CFR 1910.7. In summary, when an organization submits its application and supporting documentation, OSHA staff thoroughly reviews those materials for completeness and adequacy. When OSHA staff determines that the application is complete and adequate, an in-depth on-site review of the applicant's organization, program, staff, equipment and facilities is performed. If determined compliant to the NRTL program requirements, OSHA then publishes a notice of findings in the Federal Register for public comment.
Q: What product safety test standards do NRTLs use during the product certification evaluation process? OSHA requires an NRTL to use "appropriate" product safety standards while evaluating products for workplace safety (see Test Standard Approval Criteria in the NRTL Program Directive). OSHA utilizes industry developed and accepted standards such as: International Electro-technical Commission (IEC), Underwriters Laboratories (UL), the National Fire Protection Association (NFPA), IEEE, and ASTM International, etc., and each NRTL will have a specific “scope of standards”, approved by OSHA, dependent on the NRTL’s capabilities.
Next week, this blog will explore how a manufacturer or seller can determine whether an NRTL has certified a product, along with identifying how this applies to Electric Vehicles and Electric Vehicle Supply Equipment.
To speak with an Intertek expert on this subject matter, e-mail us at EVNews@intertek.com.